The UK Government has just closed a ‘call for evidence’ seeking views to inform the development of a new National Resilience Strategy, setting out the vision for resilience to 2030.
This process was (technically) open to anyone, so I put in my own response. It runs to slightly less than 9,000 words. The management of emergencies is something which should be important to everyone, especially after the last 18 months and in the face of a changing climate.
The call for evidence was structured into sections. I only answered relevant questions (in italics below) and fully expect that my views won’t be shared by everyone. That’s a good thing, it means we can have more debate, which is one of the biggest things that I think is missing; talking about this more openly.
- Vision and Principles
- Risk and Resilience
- Responsibility and Accountability
- Community and Local Resilience
- Resilience in an interconnected world
- Civil Contingencies Act and Supporting Guidance
Questions on Vision and Principles:
Do you agree with the proposed vision of the Resilience Strategy? Is there anything you would add, amend, or remove?
It is encouraging that the Government is reflecting on COVID experiences and has recognised that change is required.
A UK National Resilience Strategy would go some way towards meeting one of the six Sendai Framework objectives. That Framework also runs to 2030 and therefore it should be considered whether this is an opportunity to more formally set out the UKs approach to meeting the remaining objectives.
The vision reads as political manifesto rather than as actionable policy. What does the ‘most resilient nation’ mean in practice? The UK being the most resilient implies a league table situation which some nations are judged to be at the bottom of. How does the Government propose to measure and report on its resilience compared to that of other nations? The UK model is quite different to many other nations and this would make comparison tricky. This is borne out through existing international programmes such as UNISDR Resilient Cities.
Whilst a convenient image, I feel that terms like ‘bounce back’ or ‘return to normal’ don’t really capture the difficulties, challenges and complexities of the post disaster situation, and can generate a condition where learning is not a fundamental part of the process.
Do you agree with the principles laid out for the strategy? Is there anything you would add, amend, or remove?
- The recognition of the impact of vulnerability as well as risk impact and likelihood is positive. Communities are not static not homogenous and different factors influence how people respond to risk.
- Twigg (2007) offered a report to DFID with some perspectives on the characteristics of a disaster-resilient community.
- Taleb (2012) also offers some considerations on the status of being anti-fragile, which could be helpful for reframing and taking a more vulnerability informed approach.
Prevention, Mitigation and Recovery Investment
- There needs to be more national energy put in to creating a culture of learning where people feel safe to share lessons without fear of blame. Failure to learn from past incidents is well documented (Pollock (2013), Kernick (2021)) and I couldn’t see explicit references to learning in the documentation.
- The work of Resilience First (2020) is also helpful for considering the ‘ingredients and enablers’ of resilience in an urban context, but with broad applicability.
- The significant contribution of volunteers (both formal and informal) to the COVID response is evidence of untapped capacities. However, the approach needs to be sensitive and recognise that many people may have felt obligated to volunteer due to shortfalls in statutory response. Therefore ‘empowering’ could be seen as dismissive of their COVID experience.
- Similarly, sensitively managed but open and honest public debate would assist in keeping the Resilience Strategy grounded as well as manage public expectations (Braw 2021).
Questions on Risk and Resilience:
Is there more that the Government can do to assess risk at the national and local levels? If so, what?
Since being introduced there have been methodological issues with the risk assessment process. A great deal of progress has been made however, gaps remain.
I anticipate that other responses may recommend making risk information more public-friendly (i.e. risk registers should also be the vehicle to inform of actions that can be taken to mitigate and reduce risk). I disagree with this and would rather see comprehensive and technical risk assessments, the output of that analysis then being taken to inform specific risk communication products. I don’t believe that the risk register itself should be a the only risk communication channel.
The Anytown model which I initially developed in 2013 (Hogan 2013) has been used effectively in London to explore understanding of cascading failure across different sectors arising from interdependencies. This models is noted (NIST 2016) as a useful way to visualise system interdependency impacts among multi-disciplinary teams.
Significant inequity in COVID impacts has been widely reported (House of Commons 2020, ONS 2020). This is evidence that risk is a more complex and nuanced equation just the product of impact and likelihood. Consideration needs to be given to vulnerability assessments (Twigg 2007) within the wider determination of risk.
The risk assessment process and policy which follows, is also vague in relation risks which arise as a result of the action or inaction of the Government. For instance, is Brexit considered an emergency if it was a policy choice and the implications were anticipated? Similarly the inaction of the Government with regards to building safety remediation.
Is there more that the Government can do to communicate about risk and risk appetite with organisations and individuals? If so, what?
There has been a great deal of local risk-related messaging, however it may assist behaviour change if there was a nationally coordinated approach informed by risk communication evidence (for instance, Lofstedt 2010). The SF72 initiative (SF72 2021) represents an accessible and empathetic approach towards risk communication, which contrasts with more paternalistic approaches which dominate. There has been no all encompassing communication activity since the Preparing for Emergencies booklet in 2004. There are some discrete communication campaigns, lead by individual organisations (e.g. WeatherReady (Met Office 2021)) or by local resilience areas (30 Days 30 Ways UK, 2021). However it would be helpful for all of these activities to form part of a larger coordinated and coherent strategy.
The Government should put in place processes to avoid risk information being shared via the media which is only accessible via paywalls. There were many examples during COVID where important announcements were made via the broadcast press but the detail could not be accessed without a subscription. This is inappropriate.
How could the Government make risk assessment and data more accessible by frontline personnel in an emergency?
I’m unclear about the purpose of this. There needs to be more consideration of what data and information it is helpful for frontline responders to have ‘in an emergency’ as opposed to sharing that information more proactively to enable risk to be mitigated where possible.
How could the current local risk assessment process, managed through Local Resilience Forums, be strengthened to help local partners?
The Royal Academy of Engineering review into the National Security Risk Assessment is welcomed and I understand that this includes recommendations on the interface between the national and local risk assessments. There have been previous explorations of the methodology also, including recommendations in the Blackett Review (GO Science 2011) relating to the ‘reasonable worst case scenario’.
Personally, I also welcome the continual methodological changes which incorporate feedback on the process from resilience partners. However, it may be helpful to explore options for a risk management module available via Resilience Direct so that formatting changes etc can be managed centrally leaving local capacity the time to focus on the assessment and local context.
Questions on Responsibilities and Accountability:
Do you think that the current division of resilience responsibilities between Central Government, the Devolved Administrations, local government, and local responders is correct? If not, why?
The responsibilities of Local Resilience Forums have evolved but have also been confused during the response to COVID and Brexit. Government’s conception of LRF’s as ‘delivery’ bodies (Gillespie, 2020) is contrary to their stated role of being ‘cooperation’ (Cabinet Office 2013a) or ‘planning’ bodies (Cabinet Office, 2013b).
Responsibilities between different levels of response, national, regional and local, as set out in the CONOPS are out of date and require review (Cabinet Office 2013c). The CONOPS also describes levels of emergency, however this concept does not appear to translate through to any other central government emergency response policy.
I would be interested to understand how the National Situation Centre will be utilised, including how information it generates will assist response and recovery at the local level. I would welcome an update from the Government on the announcement regarding a Civil Disaster Response Taskforce (Hansard 2017) . Both of these structures sit outside of current policy and guidance and therefore it is important that there is wide understand on how they will operate.
How can the UK Central Government, DAs, local and regional forms of government and local responders better collaborate on resilience?
There is a need for trust and openness between national and local tiers and the broader emergency management profession with regards to risk and resilience arrangements. Government has no obligations under the Civil Contingencies Act and this should be addressed, perhaps by elevating all Lead Government Departments (as a minimum) to Category 2 responder status.
It is helpful that the UK Resilience Forum meeting minutes are published, however there could be greater transparency and utility made of this forum to enable organisations with national footprints to have a more sensible route for engaging.
What role, if any, should the UK Central government have in assuring that local areas are effectively carrying out their resilience responsibilities, whilst also respecting local responsibilities?
Whilst there are some indicators of good practice (Cabinet Office 2013d) for local area resilience and recently published resilience standards (Cabinet Office 2020), it would be helpful in establishing overall assessments of resilience if there were greater coherence between existing assurance mechanisms.
Use of locally elected representatives could offer another route for assurance and scrutiny of resilience arrangements. There are some examples of this (GLA 2021a) however the Government could provide central guidance on scrutiny of resilience by elected representatives.
What do you consider the advantages and disadvantages of the current legislative basis for resilience?
The CCA provides a structure for planning and assigns duties on organisations. I feel this is a more inclusive and therefore offers a more holistic approach to emergency management than creating a new agency which has power of direction over other entities, which could undermine the generally cooperative approach.
However, there have been numerous examples during the response to Brexit and COVID where plans and local capacities have not been utilised, and where new emergency legislation has been introduced when the Part 2 of the Civil Continencies Act may have been sufficient and had more opportunity for parliamentary process.
Questions on Partnerships:
Do you think that the resilience of CNI can be further improved? If so, how?
CNI resilience is typically focused on acute shocks at the expense of more chronic issues.
The age and capacity of some CNI systems and the compounding effects of resource pressures should be considered carefully.
I’m pleased in the call for evidence documentation to see references to systemic resilience. I would again point to some good practice in this area in the for of the Anytown model from London LRF (Hogan 2013, NIST 2016).
What do you think is the most effective way to test and assure the resilience of CNI? To what extent do you think regulators should play a role in testing the resilience of CNI systems and operators?
I believe that there would be huge benefits to working collaboratively with regulators/industry and local resilience areas to ensure a comprehensive approach to testing and assurance.
During an emergency, what do you think should be the role of the operators of CNI in ensuring continued provision of essential services (e.g. water, electricity, public transport)? How can the Government support CNI owners or operators during an emergency?
I would strongly recommend the Government consider increasing the responder status of some CNI operators, such as some transport providers and operators who already have well established operational ‘response’ roles and are critical to effective integrated emergency management. In an urban setting especially, there is a requirement for transport involvement in most emergency response, so that should be reflected in the legislation.
Academic and research organisations
What can the Government do to make collaboration between academic and research organisations more effective?
There need to be closer relationships between Government, Professionals and Research communities so that research can be commissioned which feeds in to national objectives, and has impactful operational impact where possible.
The independence of the academic sector needs to be respected and there should be an ability for research to be determined beyond what is helpful for UK Resilience. However, the UK could set out broad research themes and provide funding and access for research activities. One example of this is the National Institute of Health Research’s Health Protection Unit in Emergency Preparedness and Response at King’s College London (NIHR 2015).
Are there areas where the role of research in building national resilience can be expanded?
I would like to see academic accreditation of all EPC courses and other national training and the possibility of development of modular graduate programmes.
Questions on Community and Local Resilience:
Do you agree that everyone has a part to play in improving the UK’s resilience? If not, why not?
Empowering local communities to be part of the conversation about resilience and engaged at the appropriate times in response and recovery will assist in the objectives of the Resilience Strategy being met.
Do you know where to access information about emergencies that could affect you?
There needs to be a greater focus on education. Initiatives such as the London Curriculum (GLA 2021b) to provide locally specific resources and teaching materials targeted at different Key Stage levels is a good example of what could be possible. If each LRF or region could produce resources to assist school children to, for example, consider local flood risk it would embed resilience thinking and approaches at the earliest opportunity.
Have recent emergencies (e.g. COVID-19 pandemic, flooding, terrorist attacks) made you think differently about risks or changed the way you prepare for emergencies?
COVID and Brexit have made me consider resilience differently.
My main reflection is that I feel insulted that the Government demonstrated such little awareness of existing plans and/or confidence in local responders.
Are there any barriers in accessing local volunteering schemes or finding community groups that discuss local emergency planning? If so, what are the barriers?
Where volunteering worked best through COVID it was where existing relationships existed with the voluntary sector and agile local groups were able to bring capacity quickly. More coordinated approaches to regulate and control volunteering (and philanthropy) were unsuccessful because they moved to slowly.
I would encourage the Government not to discount the unseen and informal volunteering that will have taken place during the last year also.
The largest constraint relates to having sufficient resource (time and investment) to engage meaningfully with the voluntary and community sector.
Questions on Investment:
Are there examples of where investment (whether by the Government, by businesses or by individuals) has driven improvements in resilience?
The development of city resilience strategies in several UK cities was reliant on private financial support from the Rockefeller organisation.
The UK Government should make more funding available on a business case basis for specific resilience projects. This would generate innovation at a local level and would likely inform wider approaches so would have a trickle down effect. Funding for Anytown was provided by Defra as a Community Resilience project funding, but it’s application and legacy has been far beyond what was expected (Hogan 2013).
Questions on Resilience in an Interconnected World:
Where do you see the UK’s resilience strengths?
I love the diversity of the UK Resilience Sector. It’s so all encompassing that I don’t even know where it’s boundaries are. Resilience is a whole society issue and therefore the sector is and should be similarly broad. This approach can mean complexity and blurred lines, however it provides the most holistic approach.
I would have serious reservations about a move to create a UK FEMA, which would likely serve to absolve other organisations/functions of their responsibilities.
Are there any approaches taken by other countries to resilience that you think the UK could learn from?
It is possible that there is learning, but international models require research and analysis to determine applicability. It would not be effective to just lift an idea from another nation without having considered how it would be implemented in a UK context.
Which of the UK’s international relationships and programmes do you think are most important to the UK’s resilience?
The EU Civil Protection Mechanism.
What international risks have the greatest impact on UK resilience?
The Global Risk Report (WEF 2021) provides a good articulation of strategic global risk, and regularly highlights the importance of climate change and the impacts to food and water scarcity and global migration.
Questions on the Civil Contingencies Act
The CCA (section 1) defines an emergency as:
- an event or situation which threatens serious damage to human welfare in a place in the United Kingdom,
- an event or situation which threatens serious damage to the environment of a place in the United Kingdom, or
- war, or terrorism, which threatens serious damage to the security of the United Kingdom
Does the above definition reflect your understanding of an emergency, and if not how does the definition need to be expanded within the CCA?
No concerns about the definition, however it may be helpful at the outset for the definitions to include references to the prevention, mitigation and recovery phases, not just response.
Is the current designation of Category 1 and 2 responders appropriate? If not, what would be the merits of changing the identities and/or status of responders within the CCA?
Government departments should be designated as Category 2 responders as a minimum, but with some additional responsibilities regarding risk assessment.
I would also recommend that strategic transport operators, all CNI operators, strategic financial institutions, relevant parts of the justice system and the Met Office are made Category 2 responders.
I would not propose making a change to the non categorisation of the Voluntary Sector and the Military, however, it would be useful to review the guidance relating to these sectors as their positions have evolved.
Should elected local figures (e.g. Council Leaders, MPs, Metro Mayors, Police and Crime Commissioners) have greater involvement in emergency planning and preparative exercising, response and recovery and in what way?
Enhanced scrutiny on resilience matters (from elected local figures) may assist in driving progress and change through having a more open public conversation.
Are the current duties on Category 1 and 2 responders, as described in the CCA, appropriate?
The current duties are appropriate in relation to preparedness and response, however there is insufficient guidance and description of duties in the response phase or on the requirements regarding lessons learned processes.
Does the framework set out in the CCA provide sufficient clarity of the different roles and responsibilities of Category 1 and 2 responders?
The CCA is sufficiently clear in terms of its duties. However, it should be noted that responder organisations have duties outside of the CCA in relation to resilience. There would be some benefit in understanding how all the legislative aspects fit together.
Are existing mechanisms for oversight and assurance of organisations involved in resilience adequate?
Respective inspecting bodies undertake organisation or sector specific assurance. The gap is in assessing whole system resilience arrangements. There were some good attempts at this as part of the Olympics in 2012, and there was potential for the National Capabilities Survey to focus on this.
Do the arrangements as set out in the CCA provide the LRF Chair and Secretariat with sufficient means by which they can effectively coordinate contingency planning of Category 1 and 2 responders in their area?
The processes and structures are included, and barring some local variations, and generally applied consistently. However there is wide variation in available resoyrce, it’s application and local delivery. It would be helpful for the guidance relating to the operation of LRFs to be updated to match Government’s position and for there to be an greater allocation of centrally provided funding for cross-cutting issues.
A Minister of the Crown may use High Court or Court of Session proceedings to enforce duties under Part 1 of the CCA upon a Category 1 or 2 responder. Is this the right way to enforce obligations under the CCA if duties are not met?
These arrangements have not been implemented, so there is no practical evidence, but they seem appropriate.
Does the CCA sufficiently consider recovery arrangements? If not, how could this be improved?
No, the Act doesn’t even include the word recovery.
Are the responsibilities related to information sharing and cooperation sufficient for ensuring an effective multi-agency response?
Duties are appropriate for the listed organisations, however as recommended earlier, the Category 2 duties relating to information sharing should be extended to Government Departments to assist effective local planning.
Are LRFs/Strategic Coordinating Groups (SCGs) fulfilling a sufficient role in terms of planning, response and recovery? If not, what are the barriers to this?
The blurred lines between the LRF and SCG (planning/response) have been a source of concern during COVID. This implies a lack of understanding at national level about arrangements which have been developed nationally. There is a lot than can be achieved through cooperation and collaboration, and in my view LRFs do not need to be made legal bodies.
Should specific duties be placed upon central government in Part 1 of the CCA, and if so, what would these be?
Yes, I would see this as being largely similar to Cat 2 organisations but with some specific additions with regards to setting national policy and providing risk assessment information and data.
The CCA sets out strict conditions which must be met for emergency regulation to be made – this is known as the ‘triple lock’. Are these conditions still appropriate and, if not, how could the ‘triple lock’ be improved?
Emergency Regulations were not invoked under this arrangements for COVID. The Government should set out the rationale for the approach it took and provide clarity on when it sees the Part 2 arrangements being invoked. These should be tested through exercising with local level responders.
Should the regional coordinator role be retained? If yes, why is this the case, and who should be eligible to fill the position?
This role is unclear and would benefit from greater definition, linking with further clarity on Part 2 powers in general. However, anyone fulfilling such a role should be able to demonstrate suitable experience, training and qualification.
Are there institutions and positions that have come into existence after this CCA was developed which should be included in the statutory guidance? For example, Police and Crime Commissioners and Combined Authority Mayors (‘Metro Mayors’).
The range of organisations will always be dynamic. Could the Act be written in such a way as to avoid regular updates just to add organisations?
Would you like to note anything in regards to the statutory guidance of the CCA?
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